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Multimillion-Dollar Money Laundering Scheme Unraveled

A major U.S. financial institution was facing multiple government inquiries into significant cash deposits. The client engaged FTI Consulting to investigate a potential illicit scheme, quantify its scope and identify gaps in the institution’s anti-money laundering (“AML”) controls to ultimately reach a resolution with regulatory authorities, avoid the most severe of regulatory actions and return to business-as-usual.

Our Impact:

Positioned to fully cooperate with the government inquiry, the client reduced punitive damages and potential business restrictions by delivering clear and transparent findings and enacting preventative measures in response to the expanding investigation.
Control failures in the institution’s underlying processes were identified, enabling the client to overhaul its transaction monitoring system, implement specific detection scenarios and sustain risk mitigation.
The institution reached a resolution with regulatory authorities and concluded a multiyear investigation with numerous complex components, allowing the client to move on with its remediation activities and continue its operations.

Our Role:

FTI Consulting revealed the true sources of illicit funds by performing an end-to-end analysis of monetary instruments (including cashier’s checks), pinpointing critical data warehouses and source systems to validate transactions and recreating a complete history of the subjects’ bank accounts.
Our experts identified gaps in transaction monitoring rules that undercounted activity for Suspicious Activity Reports (“SARs”) — a crucial external reporting stream to alert the government to unusual activity — that ultimately led to a significant number of transactions not being escalated or reported in an accurate and timely manner.
FTI Consulting investigators identified connections between the customers and illicit activity, created relationship maps and generated intelligence critical to the institution’s understanding of the scheme, allowing for deeper cooperation with law enforcement.
The team analyzed the institution’s anti-money laundering reporting and transaction monitoring controls to identify breakdowns in compliance, monitoring and reporting processes.